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PORTLAND GOLF CLUB v. COMMISSIONER

No. 89-530.

497 U.S. 154 (1990)

PORTLAND GOLF CLUB v. COMMISSIONER OF INTERNAL REVENUE

Supreme Court of the United States.

Decided June 21, 1990.

Attorney(s) appearing for the Case

Leonard J. Henzke, Jr., argued the cause for petitioner. With him on the briefs was Allen B. Bush.

Clifford M. Sloan argued the cause for respondent. On the brief were Solicitor General Starr, Assistant Attorney General Peterson, Deputy Solicitor General Wallace, Alan I. Horowitz, and Robert S. Pomerance.

JUSTICE BLACKMUN delivered the opinion of the Court.

This case requires us to determine the circumstances under which a social club, in calculating its liability for federal income tax, may offset losses incurred in selling food and drink to nonmembers against the income realized from its investments.

I

Petitioner Portland Golf Club is a nonprofit Oregon corporation, most of whose income is exempt from federal income tax under § 501(c)(7) of...

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